Justia Wyoming Supreme Court Opinion Summaries

Appellants and the company they own filed suit against David Fisher and other defendants, alleging claims arising from an unfulfilled real estate purchase agreement. Fisher filed an answer and counterclaim. Three years later, Fisher filed for Chapter 7 bankruptcy. Appellants filed an adversary proceeding in the bankruptcy case, requesting a determination that their claims against Fisher were not dischargeable in bankruptcy. The district court subsequently dismissed Appellants’ claims. Thereafter, the bankruptcy court ruled that Appellants’ claims against Fisher were dischargeable in bankruptcy. Appellants then filed a motion to modify the district court’s order dismissing the action and a renewed motion for summary judgment. The district court denied both post-dismissal motions, noting that the matter had already been dismissed. On appeal, the Supreme Court treated Appellants’ motions as motions for relief from the dismissal order pursuant to Wyo. R. Civ. P. 60(b) and affirmed, holding that, under the circumstances of this case, the district court did not abuse its discretion in denying Appellants’ motions. View "Bartel v. West" on Justia Law

Father and Mother had a sexual encounter in Portland, Oregon. Mother became pregnant as a result of the encounter. Mother returned to her hometown of Jackson, Wyoming, where the parties’ child was born. Father remained in Washington. Father filed a petition to establish paternity, custody and support and later filed additional pleadings concerning custody and visitation. The district court granted the parties joint legal custody, awarded primary physical custody to Mother, and awarded Father visitation. The Supreme Court (1) affirmed the district court’s award of primary physical custody to Mother, holding that the custody determination was not an abuse of the court’s discretion; but (2) remanded for further proceedings so that the district court could develop a visitation plan that provides additional detail with regard to visitation and covers a longer portion of the child’s life. View "IC v. DW" on Justia Law

Appellant suffered a work-related injury while working for Employer and filed an injury report with the Wyoming Workers’ Compensation Division. The Division denied benefits, finding that Appellant had failed to show that he was authorized to work in the United States. Following an evidentiary hearing, the Office of Administrative Hearings (OAH) awarded benefits, concluding that although Appellant had submitted fake work authorization documents, Employer had a reasonable belief that Appellant was authorized to work in the United States when it hired him and, therefore, Appellant was an employee entitled to worker’s compensation benefits. The district court affirmed the OAH ruling. The Supreme Court affirmed, holding that the OAH conclusion that Appellant was an employee as defined by the Worker’s Compensation Act was in accordance with law and supported by substantial evidence. View "Gonzalez v. Reiman Corp." on Justia Law

This case concerned a dispute regarding who was entitled to the proceeds of a retirement annuity contract. Plaintiff filed a complaint for declaratory judgment pursuant to the Uniform Declaratory Judgments Act claiming that she was entitled to the proceeds. The circuit court entered summary judgment in favor of Defendant. Plaintiff appealed. The district court did not reach the merits of the case, concluding that the circuit court lacked jurisdiction over the dispute because only a district court has jurisdiction over matters brought under the Declaratory Judgments Act, no matter the amount in controversy. The Supreme Court reversed, holding (1) a cause of action seeking declaratory relief can be within the jurisdiction of the circuit court so long as the circuit court has jurisdiction independent of the declaratory relief requested; and (2) in this case, the circuit court had jurisdiction independent of the declaratory relief sought, and therefore, the court had jurisdiction to decide the declaratory judgment claim. View "Best v. Best" on Justia Law

After a jury trial, Defendant was convicted of sexual abuse of a minor in the first degree. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it denied Defendant’s motion for a mistrial based on objectionable testimony of a State’s witness, as the testimony was not so prejudicial as to warrant a mistrial; (2) the district court did not abuse its discretion when it denied Defendant’s motion for a mistrial based on testimony of a State’s witness that introduced uncharged misconduct evidence; and (3) the prosecutor’s statement in rebuttal to defense counsel’s closing argument did not constitute plain error. View "McGill v. State" on Justia Law

Mother and Father were divorced in 2009 pursuant to a divorce decree that required Father to pay seventy-five percent of the parties’ children’s medical expenses not covered by insurance. At issue in this dispute was whether the costs of one of the parties’ daughter’s placement at a residential program should be treated as a counseling cost, which pursuant to the divorce agreement would be subject to a fifty-fifty split between the parties, or as a medical expense. The district court ruled that residential treatment is a medical expense and ordered Father to reimburse Mother the amount she paid to the residential program in excess of the seventy-five/twenty-five split dictated by the parties’ divorce agreement. The Supreme Court affirmed, holding that the district court did not err in (1) failing to recognize either a written or an implied agreement between Father and Mother to split the residential treatment costs equally; and (2) failing to apply the doctrine of promissory estoppel to find a binding agreement between the parties to share equally in the costs of their daughter’s residential treatment. View "Samiec v. Hopkins" on Justia Law

Plaintiff sued Cowboy Dodge, Inc. claiming he was entitled to damages in tort because the company terminated him in retaliation for filing a worker’s compensation claim. The district court granted summary judgment in favor of Cowboy Dodge, concluding that Plaintiff had failed to make the required showing that his termination was “consequent” to filing a worker’s compensation claim. The Supreme Court reversed, holding that Plaintiff presented sufficient evidence that his filing of a worker’s compensation claim was causally related to his discharge to raise a genuine issue of material fact for trial. View "King v. Cowboy Dodge, Inc." on Justia Law

Robert Scherf suffered a heart attack at work while servicing a front end loader. Scherf died of acute myocardial infraction with cardiogenic shock. Claimant, Scherf’s widow, applied for workers’ compensation death benefits. The Wyoming Safety and Compensation Division denied benefits. The Office of Administrative Hearings (OAH) upheld the denial of benefits, concluding that although Claimant had proved a causal link between Scherf’s work exertion and the myocardial infarction, Claimant failed to prove that exertion itself was unusual or abnormal for the particular employment in which Scherf was engaged. The district court affirmed. The Supreme Court reversed, holding that the OAH conclusion that any unusual or abnormal employment exertion Scherf experienced was not unusual to or abnormal for an employee servicing heavy equipment was contrary to the overwhelming weight of the evidence. Remanded for entry of an order awarding benefits. View "Scherf v. State ex rel. Dep’t of Workforce Servs., Workers' Comp. Div." on Justia Law

Appellant had been employed for seven years by the Fremont County School District Number One when the District’s Board of Trustees terminated his employment. On appeal, Appellant asserted that the Board failed to comply with the Board’s rules of practice by untimely making its decision, and because the Board failed to take action within the time set by the rule, the Board lost subject matter jurisdiction to decide the case. The Supreme Court affirmed, holding that even if the decision was untimely, the Board did not lose jurisdiction because the rules do not specify any consequence for non-compliance and there is nothing in the rules to suggest that missing the deadline strips the Board of subject matter jurisdiction. View "Scott v. Bd. of Trs. of Fremont County Sch. Dist. Number One" on Justia Law

Plaintiffs filed a lawsuit against Defendants alleging claims for conversion and fraud stemming from one Defendant's alleged theft of beer from Plaintiffs’ store and his subsequent sale of the stolen beer to the other named Defendants. The district court granted summary judgment in favor of Defendants, finding Plaintiffs’ claims barred by the governing statutes of limitation. Specifically, the court applied the discovery rule and concluded that the statutes of limitation for fraud and conversion barred Plaintiffs’ action. Further, the court concluded that the doctrine of collateral estoppel barred Plaintiffs from litigating the question of when the statutes of limitation began to run because a federal court had dismissed Plaintiffs’ federal claims as time-barred. The Supreme Court reversed, holding (1) the district court did not err by applying the discovery rule to the fraud and conversion statutes of limitation; but (2) the doctrine of collateral estoppel did not apply in this case, and disputed issues of fact precluded summary judgment. View "Robert L. Kroenlein Trust v. Kirchhefer" on Justia Law